SBCT Final EIS - Govsupport.us
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SBCT Final EIS - Govsupport.us

SBCT Final EIS - Govsupport.us SBCT Final EIS - Govsupport.us

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Appendix D ⎯ Responses to Comments on the Draft Environmental Impact Statementidentify areas of concern. The findings of surveys performed after the 2004Transformation EIS are presented in Appendix B of this EIS.None of the activities undertaken by the Army at the BAX has damaged theHaleauau Heiau. Discussion of the Haleauau Heiau has been added to Section3.1.4.1. Please see comments 85 and 87 for more detail regarding HaleauauHeiau.124. Why is the list of cultural sites and resources identified in the DEIS incomplete?Response: The EIS has been updated to provide the list of cultural sites or resourcesfound on installations in Hawaii since the 2004 Transformation FEIS was published.The findings of these surveys are presented in Appendix C of this EIS.125. The DEIS minimizes the importance of archaeological, historic, and paleontological resourcesat the PCMS and fails to disclose the likely impacts to those resources caused by thetraining of the SBCT and what measures will be taken to mitigate the effects. The DEIS doesnot acknowledge that PCMS is an archaeological hotspot of irreplaceable value, containingthousands of archaeological resources that document several thousand years of human prehistory.The DEIS needs to disclose the extent of archaeological resources, data, and researchconducted at PCMS. Damage to or destruction of any archaeological or historic resources thatare potentially eligible for inclusion on the National Register of Historic Places or for whicheligibility is undetermined must be prohibited.Response: The Army and Fort Carson have a long standing record of Cultural Historicand Paleontological resource protection accomplished in accordance with applicablerequirements and both the SHPO and ACHP. All NRHP eligible/considered eligible resources are protected from training impacts.Archaeological and historical research has been conducted on the PCMSsince 1983. Cultural resources located on the PCMS are identified, evaluated,and protected in accordance with the NHPA, ARPA, NAGPRA, and numerousother federal and state laws, Executive Orders, and DoD/DA regulations. Approximately55,000 acres remains to be surveyed at the PCMS. Historic propertieshave been identified in the following categories: districts, buildings,structures, and historic, prehistoric, and multi-component archaeologicalsites. A total of 5,064 archeological sites have been recorded on the PCMS todate. Of these, 479 are currently determined to be eligible for inclusion in theNational Register, with 4,585 sites determined to be not eligible. Prehistoricsites number 3,893, historic sites number 690, 481 sites are multi-component,i.e. having both prehistoric and historic components, and approximately 240sites contain either historic or prehistoric rock art. There are 11 propertiesmanaged as National Register historic district-eligible: 1 Hispanic plaza settlement;6 ranching complexes; 3 stage stations; and the remnants of 1 naturalgas pipeline company town. The Cantonment area of the PCMS has been 100percent surveyed for cultural resources and is devoid of known prehistoricsites. This information has been updated in Section 3.3.4.4 of the FEIS.126. The DEIS fails to adequately disclose or consider potential effects to Native Americans.Eleven federally recognized tribes have some cultural affiliation with the PCMS region. TheDEIS recognizes that five sacred sites, three TCPs, and several rock art sites are located onFebruary 2008 D–40 2/25th SBCT Final EIS

Appendix D ⎯ Responses to Comments on the Draft Environmental Impact StatementPCMS. However, it does not consider the effects that training of the 2/25th SBCT at PCMSwould have on the tribes or TCPs.Response: Fort Carson has a mutually respected and proactive relationship with all identifiedNative American Tribal Affiliations. All TCPs, sacred sites, and Rock Artsites are protected from impact and made readily available for access by NativeAmericans consistent with both safety and military training requirements.See response to comment 83 above.127. On page 5–25, the DEIS’ reference to cultural resources surveys for only “the majority of theareas of proposed surface disturbance for the [Schofield] BAX” implicitly concedes the Armyfailed to complete such surveys prior to commencing BAX construction. The DEIS fails todisclose that this failure violated the PA. As discussed in Earthjustice’s scoping comments,the Army’s failure to live up to its commitments under the PA has already caused irreparabledamage to cultural treasures like Haleauau Heiau. Moreover, the past failures to comply withthe PA belie the DEIS’ claims that “[i]mpacts to archaeological sites can be avoided or mitigatedthrough compliance with the PA.” (DEIS at 5–26). Since the Army has demonstrated itis unwilling or unable to comply with the PA, impacts to cultural resources under AlternativeA would be much greater than disclosed in the DEIS.To take the requisite hard look at the impacts of proceeding with Alternative A, the DEISmust accurately describe the shortcomings of the Army’s mitigation measures (including disclosureof the irreparable harm to cultural resources that has already occurred as a result ofSBCT-related activities), evaluate threats to unprotected cultural sites posed by the Army’suse at QTR1 of MK19 grenade launchers (a weapon system the DEIS neither disclosed noranalyzed for use at QTR1), and accurately assess the significance of harm to cultural sites, includingburials, that stationing the 2/25 th SBCT in Hawaii would inevitably cause.Response: The Army has fulfilled its requirements under the terms of the PA for stationingSBCT at USAG-HI. All the areas of proposed surface disturbance weresurveyed in the SBMR BAX. The area was burned three or four times to allowsurvey to occur. These surveys were completed before UXO clearance began.Construction of the BAX has not commenced. The site protection measures forHaleauau Heiau were established with the input of the cultural monitors andthe earth disturbance stayed within the site protection boundaries (see photo2). Only some boulder fragments rolled on to the fencing (see photo 1). TheHeiau was not affected by earth disturbing activities or the movement of theboulders. Please refer to Section 5.2.5.2 to review the revisions.Training with the MK–19, a 40mm automatic grenade launcher, would occuron QTR 1 using only training rounds. This clarification has been added to Section2.5 in the description of the SBCT’s use of the QTR. The training roundsare non-explosive. MK-19 training on QTR1 would be within the design parametersof the range and not cause impacts more severe than were determinedin the 2004 Transformation EIS.February 2008 D–41 2/25th SBCT Final EIS

Appendix D ⎯ Responses to Comments on the Draft Environmental Impact Statementidentify areas of concern. The findings of surveys performed after the 2004Transformation <strong>EIS</strong> are presented in Appendix B of this <strong>EIS</strong>.None of the activities undertaken by the Army at the BAX has damaged theHaleauau Heiau. Disc<strong>us</strong>sion of the Haleauau Heiau has been added to Section3.1.4.1. Please see comments 85 and 87 for more detail regarding HaleauauHeiau.124. Why is the list of cultural sites and resources identified in the D<strong>EIS</strong> incomplete?Response: The <strong>EIS</strong> has been updated to provide the list of cultural sites or resourcesfound on installations in Hawaii since the 2004 Transformation F<strong>EIS</strong> was published.The findings of these surveys are presented in Appendix C of this <strong>EIS</strong>.125. The D<strong>EIS</strong> minimizes the importance of archaeological, historic, and paleontological resourcesat the PCMS and fails to disclose the likely impacts to those resources ca<strong>us</strong>ed by thetraining of the <strong>SBCT</strong> and what measures will be taken to mitigate the effects. The D<strong>EIS</strong> doesnot acknowledge that PCMS is an archaeological hotspot of irreplaceable value, containingtho<strong>us</strong>ands of archaeological resources that document several tho<strong>us</strong>and years of human prehistory.The D<strong>EIS</strong> needs to disclose the extent of archaeological resources, data, and researchconducted at PCMS. Damage to or destruction of any archaeological or historic resources thatare potentially eligible for incl<strong>us</strong>ion on the National Register of Historic Places or for whicheligibility is undetermined m<strong>us</strong>t be prohibited.Response: The Army and Fort Carson have a long standing record of Cultural Historicand Paleontological resource protection accomplished in accordance with applicablerequirements and both the SHPO and ACHP. All NRHP eligible/considered eligible resources are protected from training impacts.Archaeological and historical research has been conducted on the PCMSsince 1983. Cultural resources located on the PCMS are identified, evaluated,and protected in accordance with the NHPA, ARPA, NAGPRA, and numero<strong>us</strong>other federal and state laws, Executive Orders, and DoD/DA regulations. Approximately55,000 acres remains to be surveyed at the PCMS. Historic propertieshave been identified in the following categories: districts, buildings,structures, and historic, prehistoric, and multi-component archaeologicalsites. A total of 5,064 archeological sites have been recorded on the PCMS todate. Of these, 479 are currently determined to be eligible for incl<strong>us</strong>ion in theNational Register, with 4,585 sites determined to be not eligible. Prehistoricsites number 3,893, historic sites number 690, 481 sites are multi-component,i.e. having both prehistoric and historic components, and approximately 240sites contain either historic or prehistoric rock art. There are 11 propertiesmanaged as National Register historic district-eligible: 1 Hispanic plaza settlement;6 ranching complexes; 3 stage stations; and the remnants of 1 naturalgas pipeline company town. The Cantonment area of the PCMS has been 100percent surveyed for cultural resources and is devoid of known prehistoricsites. This information has been updated in Section 3.3.4.4 of the F<strong>EIS</strong>.126. The D<strong>EIS</strong> fails to adequately disclose or consider potential effects to Native Americans.Eleven federally recognized tribes have some cultural affiliation with the PCMS region. TheD<strong>EIS</strong> recognizes that five sacred sites, three TCPs, and several rock art sites are located onFebruary 2008 D–40 2/25th <strong>SBCT</strong> <strong>Final</strong> <strong>EIS</strong>

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